Mutual Agreement Procedure enables competent authorities to resolve treaty taxation disputes and implement agreements despite domestic time limits. A Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States lead to taxation inconsistent with the Convention to present the case to the competent authority of his residence or nationality within three years. The competent authorities shall endeavour to resolve justified objections by mutual agreement, implement any agreement notwithstanding domestic time limits, consult on interpretation or application issues, communicate directly, and, if needed, convene a Commission of representatives to reach agreement.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Mutual Agreement Procedure enables competent authorities to resolve treaty taxation disputes and implement agreements despite domestic time limits.
A Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States lead to taxation inconsistent with the Convention to present the case to the competent authority of his residence or nationality within three years. The competent authorities shall endeavour to resolve justified objections by mutual agreement, implement any agreement notwithstanding domestic time limits, consult on interpretation or application issues, communicate directly, and, if needed, convene a Commission of representatives to reach agreement.
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